20180605Answer to Vote Solar Petition.pdf

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An IDACORP Company
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LISA D. NORDSTROM
Lead Counsel
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June 5, 2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-17-13
New Schedules for Residential and Small General Service Customers with
On-Site Generation - ldaho Power Company's Answer to Vote Solar's
Petition for Reconsideration
Dear Ms. Hanian.
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Answer to Vote Solar's Petition for Reconsideration.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:kkt
Enclosures
P.O. Box 70 (83707)
1221 W. ldaho 5t.
Boise, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
!daho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n o rd strom @ i d a hopowe r. com
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORIry TO ESTABLISH NEW
SCHEDULES FOR RES!DENTIAL AND
SMALL GENERAL SERVICE
CUSTOMERS WITH ON-SITE
GENERATION
REC EIVEI)
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ON5b
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
ANSWER TO VOTE SOLAR'S
PETITION FOR
RECONSIDERATION
On July 27,2017, ldaho Power Company ("!daho Power" or "Company") applied to
the ldaho Public Utilities Commission ("Commission") requesting an order approving the
establishment of separate customer classes for residential and small general service
("R&SGS") customers with on-site generation. The Commission approved the creation of
Schedule 6, Residential Service On-Site Generation, and Schedule 8, Small General
Service On-Site Generation ("Schedules 6 and 8") in Order No. 34046 ("Order") issued on
May 9, 2018.
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 1
On May 29,2018, Vote Solar served a Petition for Reconsideration ("Petition"). ln its
Petition, Vote Solar argues that new Schedules 6 and 8 should apply only to customers who
export electricity.t
Idaho Power, in accordance with ldaho Code S 61-626 and RP 331.05, files this
Answer opposing the Petition. ldaho Power believes Vote Solar's argument is flawed for
two reasons: (1) the load service requirements for on-site generation systems connected in
parallel with ldaho Power's system are different than customers without on-site generation,
and (2) Vote Solar's recommendation would be unenforceable given that Idaho Power does
not measure excess generation separately from consumption.
Establishing the appropriate application of Schedules 6 and 8 is important for the
longterm integration of on-site generation. The Company believes the Commission's Order
and the approved tariff schedules appropriately establish the scope of the customers to be
included in the newly established classes.
l. Load Service Requirements for Parallel-Connected Svstems
ln its case, ldaho Power presented evidence to show that the load service
requirements and usage characteristics of a customer with on-site generation are
fundamentally different than that of a customer without on-site generation. Mr. Dave Angell
explained in his rebuttal testimony that customers with on-site generation are partial
requirements customers, that is, they generate all or some of their own electricity. This is
true even if the customer does not export excess generation.z When asked how the load
1 Vote Solar requested that "the Commission instead require the Company to revise the new Schedules
6 and 8 to apply only to customers who export electricity. Petition at 1.
2 Vote Solar's statement on page 5 of the Petition that "effect on circuits, voltage management,
islanding, and load cycle adjustments - do not apply to customers who do not export" is not true because these
customers continue to require the ancillary services described in Mr. Angell's direct testimony.
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 2
service requirements of a customer with on-site generation differs from that of a standard
service customer, Mr. Angell testified
The load service requirements of a customer with on-site
generation is fundamentally different than that of a customer
without on-site generation. Customers with on-site generation are
"partial requirements" customers. A partial requirements
customer is one who generates all or some of their own electricity.
The utility provides only part of the customer's energy needs.
Partial requirements customers still require a variety of services
from the utility even though they provide some or all their own
energy. So long as these customers remain connected to the
utility, they continue to take other services from the utility. As
described in my direct testimony, the ancillary services they
require typically include: capacity to meet the in-rush current
requirements for starting motor loads such as air conditioning
compressors, supplemental services when solar is not available
at night, and frequency services to maintain power quality. ldaho
Power can economically provide partial requirements service that
allows customers with on-site generation flexibility in meeting
their energy needs with the reassurance that the utility is available
to handle all their electrical needs should their on-site generation
be interrupted or fail.s
ldaho Power believes the distinction of a parallel connection is the appropriate
qualification criteria for inclusion in the newly established classes. Per their Applicability
sections, Schedules 6 and 8 apply only to on-site generation systems connected in parallel
to ldaho Power's system.r As defined in both tariff schedules, "parallel connection means
generating electricity from an on-site generation system that is connected to and receives
voltage from ldaho Power's system."s lf the system is connected in parallel to ldaho Power's
system, the customer is capable of exporting energy to the grid, and therefore, the parallel
connection is the appropriate criteria upon which inclusion in new Schedules 6 and 8 is
3 Tr. at 598, l. 17 through 600, l. 15.
4l.P.U.C. No.29, Tariff No. 101, Schedules6 and 8 (approved May21,2018 effective June 1,2018)
s l.P.U.C. No. 29, Tariff No. 101, p. 6-2 and p. 8-2.
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 3
based, not whether a customer exports excess energy. lt is not adequate to depend on a
customer configurable device, such as a dynamically controlled inverter, a grid tie limiter, or
a grid inverter with export control, because the device could be reconfigured at any time to
allow the customer to export energy.
To be clear, it is not ldaho Power's intent to require R&SGS customers with on-site
generation who are not connected in parallel to take service under Schedules 6 and 8 as
they are incapable of exporting energy to the grid. An on-site generation system that is
isolated from the grid with non-parallel operations is not served by ldaho Power and
therefore would not be required to take service under new schedules 6 and 8. An example
of this would be a customer with a backup generation system. The customer's automatic
transfer switch is configured to isolate the customer load from the electric distribution system
when it senses very low or no voltage. The customer takes service either from the isolated
on-site generation system or from the utility.
Because all R&SGS customers who operate an on-site generation system in parallel
with ldaho Power's system are partial requirements customers, it is appropriate to include
all R&SGS customers whose systems are connected in parallel with ldaho Power's system
in Schedules 6 and 8 -- even if no energy exports occur. The "partial" nature of the load
service requirements justifies a separate rate structure from that of standard service
customers to reflect the distinctly different use of ldaho Power's system.
ll. lntra-Hour Usaqe Not Detectable in Net Hourlv Consumption
Even if the Commission granted Vote Solar's request, using the export of electricity
as the criterion to determine the applicability of Schedules 6 and 8 is not enforceable
because intra-hour usage is not detectable. As explained by Mr. Tim Tatum during cross-
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION .4
examination, ldaho Power's R&SGS customers with on-site generation have one meter that
measures net consumption. Customer generation is not measured separately from
consumption. Mr. Tatum testified: "We don't have metering that captures gross
consumption. We have meters that capture net consumption."o Consequently, ldaho Power
cannot detect the exported energy if the net result at the end of every hour is greater than
or equal to zero; the exported energy, which is less than the amount of energy consumed,
is masked over the course of every hour.
Mr. Tatum explained the reason why recording net consumption would not provide
the granularity necessary to see if, at any moment, the customer had exported electricity to
ldaho Power's system. He testified "on a moment-by-moment basis, there is that back and
forth sort of interaction. lt's just that you can't see it [the back and forth interaction] when
you're measuring it on even an hourly interval. [T]here were positives and negatives going
on throughout the entire hour...."7
While Vote Solar argues there is no basis for including customers who are not
bidirectional, ldaho Power disagrees with Vote Solar's assertion that "there was no evidence
presented by any party about the load characteristics of customers with behindthe-meter
generation but who do not export."8 During his cross-examination, Mr. Tatum indicated that
all of ldaho Power's R&SGS customers with on-site generation systems have exported
excess energy at some time during the life of their system. When asked by Mr. Bender:
"And you don't have any load data for what a load shape for that type of customer with
6 Tr. at 363, ll. 1-3.
7 Tr. at 378, ll. 15-18.
I Vote Solar's Petition at 6.
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION .5
battery storage and no exports looks like; is that right?", he testified. "l do not, no, and /'m
not aware of the Company having any such customer to evaluate."s
Given that intra-hour exports are undetected, Vote Solar's request to use energy
exports as the criteria for inclusion in new Schedules 6 and 8 is not enforceable.
Furthermore, to date, all R&SGS customers whose on-site generation systems are
connected in parallel to ldaho Power's system have exported excess energy to the grid.
lll. Conclusion
It is appropriate to include all R&SGS customers whose systems are connected in
parallel with ldaho Power's system in Schedules 6 and 8 - even if no energy exports occur;
this would include any systems with the capability to export energy. The export of electricity
is not an appropriate criterion for determining the applicability of Schedules 6 and 8 because
(1) the load service requirements for on-site generation systems with a parallel connection
are different than customers without on-site generation, and (2) Vote Solar's
recommendation to use the export of electricity as the criterion to determine the applicability
of Schedules 6 and 8 would be unenforceable. Moreover, establishing the appropriate
application of Schedules 6 and 8 is important for the long-term integration of on-site
generation.
The Company believes the Commission's Order in this matter, and the tariff
schedules approved in this case, appropriately establish the scope of the customers to be
included in Schedules 6 and 8 as all customers whose on-site generation system is
connected in parallel to ldaho Power's system. Consequently, and pursuant to the
s Tr. at 349, ll. 19-20 (emphasis added). ln response to ldaho Clean Energy Association's First
Production Request, Request No. 1, ldaho Power performed a review of its existing R&SGS customers with
on-site generation and found that all customers had exported excess energy to the grid at some time over the
life of their system.
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 6
reasoning set forth above and in evidence in the record, ldaho Power respectfully requests
the Commission deny Vote Solar's Petition for Reconsideration.
Respectfully submitted this Sth day of June 2018.
L!
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 7
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 5th day of June 2018 I served a true and correct copyof IDAHO POWER COMPANY'S ANSWER TO VOTE SOIAR'S PETITION FOR
RECONSIDERATION upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conseruation League
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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erin. ceci l@arkoosh. com
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 8
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Glean Energy Association
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
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den@qivenspu rsley. com
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IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION - 9
Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
P.O. Box 1308
Boise, ldaho 83701
Intermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON MoCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84111
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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wwi lson @snakeriveral I iance. orq
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Ki n{be r[ t ot(glt, Executive Ass ista nt
IDAHO POWER COMPANY'S ANSWER TO VOTE SOLAR'S PETITION FOR RECONSIDERATION . 1O